NUREG-1431, Forwards RAI Re Proposed Amend to TS for Byron & Braidwood Stations,To Be Consistent W/Improved TSs in NUREG-1431, STS-Westinghouse Plants, Rev 1.Requests Response to RAI within 30 Days of Date of Ltr

Forwards RAI Re Proposed Amend to TS for Byron & Braidwood Stations,To Be Consistent W/Improved TSs in NUREG-1431, STS-Westinghouse Plants, Rev 1.Requests Response to RAI within 30 Days of Date of Ltr

ML20217N991
Person / Time
Site:	Byron, Braidwood
Issue date:	04/29/1998
From:	Assa R NRC (Affiliation Not Assigned)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
RTR-NUREG-1431 TAC-M97546, TAC-M97547, TAC-M97548, TAC-M97549, NUDOCS 9805060024
Download: ML20217N991 (11)

Text

!

l April 29, 1998 Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company I Executive Towers West lli.

1400 Opus Place, Suite 500 Downers Grove, IL 60515

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 (TAC NOS. M97548, j M97549, M97546 AND M97547).

1

Dear Mr. Kingsley:

l On December 13,1996, Commonwealth Edison Company (Comed) proposed to amend the technical specifications (TS) for Byron Station, Units 1 and 2, and Braidwood Station, Units 1 .

and 2, to be consistent with the improved TS in NUREG-1431, " Standard Technical  !

Specifications - Westinghouse Plants,' Revision 1. During the course of our review, we have identified the need for further information as discussed in the enclosed request for additional information (RAl). This request seeks to clarify Section 3.8.

To support the NRC staff's review schedule, your written and electronic response to this RAI is requested within 30 days of the date of this letter. Should you have any questions, please l contact me at (301) 415-1391.

' Sincerely, ,

ORIG. SIGNED BV:

Ramin R. Assa, Project Manager Project Directorate 111-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, i STN 50-456, STN 50-457

)

Enclosure:

RAI cc w/ encl: see next page  !

1

~ DISTRIBUTION: i Docket PUBLIC PDill-2 r/f EAdensam SRichards '

CMoore RAssa JHickman OGC,015818 ACRS, T2E26 piM l

' MJordan, Rlli - SBailey  !

DOCUMENT NAME: G:\CMNTJR\ BRAID-BY\BB97548.RAI To receive a copy of this document, indicate in thebox: -C" = Copy w/o encls "E" = Copy w/encls "N"= No copy i OFFICE PM:PD3h 6 W33-2 &D:PD3-2 l4 ,

I NAME RASSA T h &l@$QRE SRICHARDS CfV I DATE 04/19 /98 OT/9 /98 04/ #1 /98 OFFICIAL RECORD COPY

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9005060024 900429 PDR ADOCK 05000454 g

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g 568 %g% UNITED STATES l g j t

NUCLEAR REGULATORY COMMISSION o WASHINGTON, D.C. 2006H001 i s., ...../

April 29,' 1998 Mr. Oliver D. Kingsley, President l Nuclear Generation Group i

Commonwealth Edison Company Executeve Towers West lli 1400 Opus Place, Suite 500 l

Downers Grove, IL 60515

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 (TAC NOS. M97548, M97549, M97546 AND M97547)

Dear Mr. Kingsley:

On Dect mber 13,1996, Commonwealth Edison Company (Comed) proposed to amend the technical specifications (TS) for Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, to be consistent with the improved TS in NUREG-1431, " Standard Technical Specifications - Westinghouse Plants," Revision 1. During the course of our review, we have identified the need for further information as discussed in the enclosed request for additional information (RAl). This request seeks to clarify Section 3.8.

I To support the NRC staff's review schedule, your written and electronic response to this RAI is requested within 40 days of the date of this letter. Should you have any questions, please contact me at (301) 415-1391.

Sincerely, m ,

Ramin R. Assa, Project Manager l Project Directorate lll-2 t

Division of Reactor Projects - til/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, l . STN 50-456, STN 50-457

Enclosure:

RAI cc w/oncl: see next page l'

l O. Kingsley . Byron /Braidwood Stations .

Commonwealth Edison Company cc: ,

Ms. C. Sue Hauser, Project Manager George L. Edgar Westinghouse Electric Corporation Morgan, Lewis and Bochius Energy Systems Business Unit 1800 M Street, N.W.~

Post Office Box 355 Washington, DC 20036 Pittsburgh, Pennsylvania 15230 Attomey General Joseph Gallo 500 S. Second Street Gallo & Ross Springfield, Illinois 62701 1250 Eye St., N.W., Suite 302 Washington, DC 20005 lilinois Department of Nuclear Safety Office of Nuclearcacility Safety Michael 1. Miller, Esquire. 1035 Outer Park Drive Sidley and Austin _

Springfield, Illinois 62704 One First National Plaza Chicago, Illinois 60603 Commonwealth Edison Company Byron Station Manager .

Howard A. Leamer 4450 N. German Church Road Environmentallaw and Policy Byron, Illinois 61010-9794 Center of the Midwest 35 East Wacker Dr., Suite 1300 Commonwealth Edison Company Chicago, Illinois 60601 Site Vice President - Byron 4450 N. German Church Road U.S. Nuclear Regulatory Commission Byron, Illinois 61010-9794 Byron Resident inspectors Office l

. 4448 N. German Church Road U.S. Nuclear Regulatory Commission  ;

Byron, Illinois 61010-9750 Braidwood Resident inspectors Office  ;

RR 1, Box 79 ,

Regional Administrator, Region ill Braceville, Illinois 60407 U.S. Nuclear Regulatory Commission 801 Warrenville Road Mr. Ron Stephens Lisle, Illinois 60532-4351 lilinois Emergency Services and Disaster Agency Ms. Lorraine Creek 110 E. Adams Street RR 1, Box 182 Springfield, Illinois 62706 Mantono, Illinois 60950 Chairman Chairman, Ogle County Board Will County Board of Supervisors Post Office Box 357 Will County Board Courthouse Oregon, Illinois 61061 Jo:iet, Illinois 60434 Mrs. Phillip B. Johnson Commonwealth Edison Company 1907 Stratford Lane Braidwood Station Manager Rockford, Illinois 61107 RR 1, Box 84 Braceville, Illinois 60407

1

,- O. Kingsley Commonwealth Edison Company - Byron /Braidwood Stations .

Ms. Bridget Little Rorem Ms. Irene Johnson, Licensing Director Appleseed Coordinator - Nuclear Regulatory Services

' 117 N. Linden Street Commonwealth Edison Company Essex, Illinois 60935 , Executive Towers West lli 1400 Opus Place, Suite 500 Document Control Desk-Licensing Downers Grove, IL 60515 Commonwealth Edison Company 1400 Opus Place, Suite 400 Commonwealth Edison Company Downers Grove, Illinois 60515 /

Reg. Assurance Supervisor- Braidwood RR 1, Box 79 Commonwealth Edison Company Braceville, Illinois 60407 Site Vice President - Braidwood RR 1, Box 64 _

Commonwealth Edison Company Braceville,IL 60407 Reg. Assurance Supervisor- Byron 4450 N. German Church Road Mr. David Helwig Byron, Illinois 61010-9794

,- Senior Vice President Commonwealth Edison Company Mr. Michael J. Wallace Executive Towers West I'l Senior Vice President 1400 Opus Place, Suite 900 Commonwealth Edison Company Downers Grove,IL 60515 Exccutive Towers West lli 1400 Opus Place, Suite 900 Mr. Gene H. Stanley Downers Grove, IL 60515 PWR's Vice President Commonwealth Edison Company Executive Towers West til 1400 Oous Place, Suite 900 Downers Grove, IL 60515 Mr. Steys Perry BWR's Vice President Commonwealth Edison Company Executive Towers West lli 1400 Opus Place, Suite 900 Downers Grove, IL 60515

- Mr. Dennis Farrar Regulatory Services Manager Commonwealth Edison Company Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove, IL 60515

1 i

I

! Byron & Braidwood Improved TS Review Comments ITS Section 3.8, Electrical Power Systems ITS 3.8.1 -

3.8.1-1 DOC A2

.The discussion in DOC A2 is not consistent with Insert 3.8-2D or with ITS 3.8.1 Condition  ;

G. Is the DOC or the LCO and the Insert correct? I 3.8.1-2 JFD BP45 Insert B 3.815A is consistent with the ITS Bases .1iscussion for ITS 3.8.1 Condition G. I However, the inclusion of the two DG inoperable example is not helpful in explaining the l condition because that example does not e.xplain the level of equipment operability at which the Condition must be entered.

3.8.1-3 DOC LA4 The DOC states "This change is required to properly reflect the manufacturer's current recommendation ..." and "the manufacturer is indifferent to the benefits of this type of start" What is the documented basis for these statements?

l 3.8.1-4 DOC L8 The discussion states "... end eliminating an upper voltage criteria ..." What voltage criteria are eliminated?

l 3.8.1-5 DOC M11 1

The CTS markup (CTS 4.8.1.1.2.f.2 ) of the voltage values (-420, + 210) results in values '

that are inconsistent with those in ITS 3.8.1.9.

'l 3.8.1-6 Bases JFD P36 The JFD does not appear to be applicable in the markup of the second paragraph of STS Bases page B 3.8-9.

3.8.1-7 Bases JFD B1 and insert B 3.8-27A (Bases JFD P21)

The markup of the STS Bases for SR 3.8.1.3 eliminates the discussion of power factors (STS B 3.8-13) and substitutes a discussion of DG operation from 0 to 1000 kVars. Use of Bases JFD B1 is not apprcpriate and if Beses JFD B3 was intended, a justification of the O to 1000 kVars range shou'd be provided as it does not appear in the CTS. Likewise, while Bases JFD P21 makes the case for discor,tinuing testing at rated power factor, it fails to provide any technical basis for the guidance provided in Insert B 3.8-27A.

BB2_CR_3.8 1 April 16,1998 ENCLOSURE

I Byron & Braidwood improved TS Review Comments j ITS Section 3.8, Electrical Power Systems 1 3.8.1-8 ITS 3.8.1 1

l Changing of "offsite" circuit to " qualified" circuit appears to be a problem without the carryover of the CTS qualification of "Each units System Auxiliary Transformer bank energized from an independent transmission circuit." The ITS LCO Bases state that a qualified circuit is as defined in the FSAR yet, the discussion then goes on to state in l

( tabular form what the two qualified circuits are. The problem with that discussion is that '

l there is no assurance of the SATs being energized from independent transmission' circuits.

In fact, the iTS 3.8.1 Bases Background states, in part ".. switchyard ara maintained in accordance with the UFSAR and are not (emphasis added) governed by the requirements of

. Technical Specifications." Both the words of the STS and those of the CTS assure that independence will be maintained while the ITS does not. (Note: Qualified circuit has also i

been substituted into other places in the ITS).

3.8.1-9 DOC L2 The DOC states "This backup source of power is not credited in any design basis event and is not needed to preclude any new or different accident." That statement does not adequately explain why, if that is the case, the requirment still ended up in the CTS. Was

! it included for any extended action time or other consideration elsewhere in the CTS?

l. 3.8.1-10 DOC L3 l' This DOC explains the two relaxations but provides no basis for why either is acceptable.

3.8.1 11 ITS SR 3.8.1.3 Note 1 In the ITS, the use of the manufacturer's recommendations is permissive. However, in CTS 4.8.1.1.2.a.5 the test must be done in accordance with the manufacturer's L recommendations. There is no discussion supporting this less restrictive change.

3.8.1 12 DOC LA6 i

The acceptable load range values (greater than or equal to 4950 KW and less than or equal to 6050 KW) are not consistent with the CTS footnote 6050 (+0, -150) or the values in

'ITS SR 3.8.1.14. The ITS SR values are consistent with the ITS SR Bases which in turn make the Bases inconsistent with LA6. What are the correct numbers?

3.8.1-13 DOC L10 The DOC states "No analyzed event credits the use of the cross connect for DG operation

... " That does not explain why it still ended up in the CTS.

BB2_CR_3.8 2 April 16,1998 L

Byron & Braidwood Improved TS Review Comments ITS Section 3.8, Electrical Power Systems

3.8.1 DOC LA10 t

L The DOC states "This capability is not a credited function for any assumed design basis event ..." Again this does not explain why it still ended up in the CTS.

3.8.1 15 DOC L15-Is this change considered less restrictive'because in the CTS loss of power would require a 2 square inch vent while the ITS allows the RHR suction relief or other paths that do not

! ' rely on power to be used? If that is the case, isn't that just letting the LTOP TS control? If so, why isn't this an sdministrative change?

l 3.8.1-16 ITS LCO 3.8.1 and insert 3.8-98 ITS LCO 3.8.1. states the DGs are capable of supplying "the ... System." Insert 3.8 98

, makes ITS LCO 3.8.2 state two DGs capable of supplying "one division of ... subsystems."

l STS LCO 3.8.1 states two DGs " capable of supplying the onsite IE .. subsystems." In

order to make it clear that each DG supplies subsystems (consistent with the STS and LCO l_ 3.8.2) ITS 3.8.1 should read " two DGs each capable of supplying one division of ... the l Class IE power distribution system."

3.8.1-17 JFD P25 CTS requires the diesel to start from " ambient" and the STS requires from " standby" conditions for SRs 3.8.1.2,11,12,19, and 20. It is correct as stated that as the terms are used, they mean the same. However, using neither term in the'lTS would allow any of the above tests to be run in a situation where the diesel was already at or about full operating temperatures. The STS language should be adopted to ensure that these tests are done only from true standby / ambient conditions.

3.8.1 18- Insert to Bases for ITS SR 3.8.1.16 The bases discussion has been modified to state the SR is in general conformance with the l recommendations of Reg Guide 1.9 paragraph 2.2.11. How is this reflected in the discussion.of Reg Guide 1.9 contained in FSAR Appendix A7 -That discussion doec not appear to contain any qualifications with respect to this testing, j 3.8.1-19 DOC L28 and JFD P22 j identified as Beyond Scope item #11 BB2_CR_3.8 3 April 16,1998 g l

I

Byron & Braidwood improved TS Review Comments ITS Section 3.8, Electrical Power Systems

3.8.1-20 DOCS L26 and L29, and JFDs P21 and P23 Identified as Beyond Scope item #12 3.8.1-21 DOC L24 and JFD P23 Identified as Beyond Scope item #13 3.8.1-22 JFD P9 This JFD is applicable to LCOs 3.8.2 and 3.8.7, it is unclear why it is used in the markup of STS 3.8.1 (Page 3.8-4).

3.8.1-23 Bases for ITS SR 3.8.1.3 Given that the second paragraph of the Bases says that there are no power factor requirements and that the DG is normally operated between 0 and 1000 kVars, wouldn't it be better to modify the discussion in the last paragraph to remove the power factor discussion or change it to kVars discussion?

lTS 3.8.2 l

i 3.8.2-1 DOC A14 The intent of ITS Conditions A and B should be to return the inoperable battery charger to operable status and once returned to that status break the cross-tie with the other unit and begin to use that charger. As proposed in DOC A14,if the charger could be operable sooner than the required Completion Time the cross-tie would not have to be broken for up ~

to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />. That may not have been the intent but giving the cross-tie a separate Completion Time certainly makes that reading a reasonable one.

3.8.2-2 JFD C10 Staff has not seen or reviewed changes proposed by WOG-81.

3.8.2-3 JFD P21 and Bases JFD P26 The LCOs and Bases for STSs 3.8.2,3.8.8, and 3.8.10 have been modified by adding a ,

note stating "LCO 3.0.3 is not applicable". If this is a generic issue a generic change l should be proposed for the NRC to consider. On a plant specific basis it is beyond the ]

j scope of the conversion. i l

l 1 i l

BB2_CR_3.8 4 April 16,1998 l

L i

1 Byron & Braidwood improved TS Review Comments ITS Section 3.8, Electrical Power Systems ITS 3.8.3 1

3.8.3 -1 JFD C1 l Staff approval of TSTF-2 Rev 1 is pending.

l l ITS 3.8.4 l

3.8.4-1 ITS 3.8.4 Bases Background in the Background discussion, the word " generally" has been added when discussing conformance with Reg Guide 1.6 and IEEE 308. Byron & Braidwood FSAR Section 8.1 and FSAR Appendix A do not appear to contain any exceptions to either of the standards with j respect to DC electrical power. What requires the insertion of the " generally" qualifier? ,

l 3.8.4-2 Bases JFD P30 in the ITS Bases the phrase "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" is deleted. While 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> may not be  ;

appropriate for Byron & Braidwood, Sections 5 and 6 of IEEE 308 require that the battery charger time be within a time consistent with the design basis and that the battery charging available. Therefore, the charging time for Byron & Braidwood should be available and should be put in place of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.8.4-3 Insert 3.8.24A

)

1 Why is ITS_ Condition B "that has an inoperable battery charger ..." and Condition C "with  !

an inoperable source ..."?

3.8.4-4 ITS SR 3.8.4.7 (Byron only) & JFD P28 and Bases JFD P35 The STS state that a modified discharge test can be substituted for a service test but not with a discharge performance test as specified in the ITS SR. Further, JFD P28 states 1 (quoting IEEE 450) "a modified performance discharge test can 'be used in lieu of a service I test at anytime" This implies that if a performance discharge test can be used (which would be contrary to the STS Bases) it could only be used on some limited basis and not the unlimited basis proposed. Finally, use of the performance discharge test in place of the service test appears contrary to the Reg Guide 1.129 discussion in the Byron & Braidwood 1

. FSAR Appendix A. Further explanation and justification is needed. j 3.8.4 5 ITS 3.8.4 Bases References (Braidwood)

It appears that there should be an additional page following B3.8-58a containing the section references. I h

j BB2_C R.,3.8 5 April 16,1998 '

Byron & Braidwood Improved TS Review Comments j ITS Section 3.8, Electrical Power Systems j l

l l

3.8.4-6 ITS 3.8.4 Bases References (Byron) lEEE 450 -1995 is the version of the standard in the Reference section and is the referenced standard for the discussion of frequency and acceptance criteria for a number of the ITS 3.8.4 (and 3.8.6) SRs. However, the Byron UFSAR states that the frequencies of battery tests are established in accordance with IEEE 450 -1975 (as modified by the

proposed 1978 revision). Do the references to different version of the standard create any l inconsistencies in application of the SRs and/or are there other instances in which the ITS updates standards from those in the FSAR?

I 3.8.4-7 Bases JFD P18 I STS 3.8.4.6 recommends that specific battery ratings be provided in the SR. However, consistent with CTS SR 4.8.2.1.2.c.4, the wording "a load equal to manufacturer's rating" I' is adopted in the ITS (JFD P16). Consistent with that change, it is proposed that the ITS Bases contain the same wording, if the Bases merely repeat the words of the TS, how is a basis for the TS being provided? Why isn't a specific value (which can be modified n.

accordance with the Bases control program) provided in the Bases?

ITS 3.8.5 3.8.5 1 JFD C9 TSTF 204 has not yet been approved by the NRC.

4 ITS 3.8.6 3.8.6-1 Bases JFD P46 TSTF 203 has not yet been approved by the NRC.

3.8.6-2 DOC L19 The DOC states that ITS SR 3.8.6.3 requires "this same verification ..." when referring to CTS SR 4.8.2.1.2.b.3. However, the CTS requires that the average temperature of all connected cells be checked, while the ITS requires only the average temperature of reoresentative cells be checked. This less restrictive change has not been justified.

ITS 3.8.7 3.8.7-1 JFD P18 and Bases JFD P43 TSTF 202 has not yet been approved by the NRC.

BB2_C R_3.8 6 April 10,1998 l

t

l Byron & Braidwood improved TS Review Commonts ITS Section 3.8, Electrical Power Systems ITS 3.8.8 No comments ITS 3.8.9 3.8.9-1 JFD C4' '

How was the editorial comment provided to the NRC.

3.8.9-2 DOC L18 On a generic basis the change proposed here was rejected when the staff considered TSTF 16. If arguing for it on a plant specific basis it is beyond the conversion scope.

ITS 3.8.10 No comments BB2_C R_3.8 7 April 16,1998